This Privacy Policy explains how Hoolume (“Hoolume,” “we,” “us,” or “our”), a service operated by [Precena Strategic Partners Pte. Ltd. / relevant Precena entity] (“Precena,” “Company”), incorporated in Singapore, collects, uses, discloses, and protects information about users of the Hoolume website, mobile applications, and learning platform (collectively, the “Services”)
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Hoolume provides subscription-based leadership and management training, including self-paced e-learning courses, an AI Coach chatbot feature, and related coaching and community tools, to individual subscribers (B2C) and corporate clients (B2B) globally.
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By accessing or using the Services, you agree to the collection and use of information in accordance with this Privacy Policy. If you do not agree, please do not use the Services
This Policy applies to all users of Hoolume, regardless of location. Because Hoolume operates globally, we have designed our privacy practices to meet the requirements of Singapore's Personal Data Protection Act 2012 (“PDPA”) as our baseline standard, while also incorporating protections consistent with other applicable data protection laws, including the EU/UK General Data Protection Regulation (“GDPR”) and the California Consumer Privacy Act (“CCPA”), where those laws apply to you.
- Account information: name, email address, phone number, password, company/employer (for B2B users), country of residence.
- Billing information: billing address and payment details, processed via our third-party payment processor (see Section 5).
- Profile and learning information: job title, seniority level, learning goals, course progress, quiz/assessment results, certificates earned.
- Content you submit: reflections, workshop assignments, community posts, feedback, and support inquiries.
- AI Coach chatbot inputs: messages, questions, and other content you submit to Hoolume's AI Coach feature (see Section 4).
- Fellowship/grant eligibility information: country of residence and billing country, used to verify eligibility for regional pricing tiers.
- Usage data: pages viewed, courses accessed, time spent, click patterns, and interactions with the Services.
- Device and log data: IP address, browser type, device identifiers, operating system, and general location (derived from IP address).
- Cookies and similar technologies: used for authentication, preferences, analytics, and fraud prevention (including verifying your bank/billing country against your access location for regional pricing eligibility, as described in our Terms and Conditions).
- Our learning management platform provider, LearnWorlds, which hosts course content and processes learner activity on our behalf.
- Our payment processor, which shares limited transaction data (e.g., payment status, last four digits of card, billing country) needed to manage your subscription.
- Corporate administrators, where you are enrolled by an employer or client organisation for B2B training.
We use personal data for the following purposes: - To create and administer your account and subscription (including the 90-day Semester model and billing cycles).
- To deliver, personalise, and improve the Services, including course recommendations and learning- progress tracking.
- To operate the AI Coach chatbot and generate responses to your queries (see Section 4).
- To process payments, apply the correct pricing tier (including Global Fellowship grant pricing), and prevent misuse of regional pricing (e.g., verifying billing country against access location).
- To communicate with you, including service updates, course reminders, and marketing communications (which you may opt out of at any time).
- To maintain the security and integrity of the Services, including detecting fraud and unauthorised access.
- To comply with legal obligations and enforce our Terms and Conditions.
Hoolume offers an AI Coach chatbot feature that uses standard large language model (“LLM”) technology provided by third-party AI model providers to process your inputs and generate responses.
- What is shared: messages and other content you submit to the AI Coach are transmitted to our LLM provider(s) solely to generate a response and, where applicable, to improve the relevance of that response within your session.
- No professional advice: the AI Coach provides general guidance for learning and reflection purposes only. It is not a substitute for professional psychological, legal, financial, medical, or HR advice, and its responses may be inaccurate or incomplete.
- Data retention: conversation inputs and outputs may be retained to maintain conversation history within your account, improve the AI Coach feature, and for safety and abuse-monitoring purposes, in accordance with the retention practices described in Section 8.
- Avoid sensitive disclosures: please do not share sensitive personal data (e.g., health information, financial account numbers, government identification numbers) in your conversations with the AI Coach unless necessary and appropriate.
- Model providers: we engage reputable third-party AI/LLM providers under contractual terms that restrict their use of your data to providing the service to Hoolume, and prohibit use of your inputs to train their general-purpose models, except where you have separately consented or where required for safety and legal compliance.
- Human oversight: we may review anonymised or aggregated AI Coach interactions to improve quality, safety, and training content design.
We do not sell your personal data. We share personal data only in the following circumstances:
- Service providers: including LearnWorlds (learning platform hosting), our payment processor (billing and subscription management), our AI/LLM provider(s) (AI Coach functionality), email and communications providers, and analytics providers — each under contractual obligations to protect your data and use it only for the purposes we specify.
- Corporate clients: where you access Hoolume through an employer or client organisation, we may share your course progress and completion data with your organisation's designated administrator.Legal and safety: where required by law, regulation, legal process, or governmental request, or to protect the rights, property, or safety of Hoolume, our users, or others.
- Business transfers: in connection with a merger, acquisition, financing, or sale of assets, subject to appropriate confidentiality protections
As a global service, your data may be transferred to, stored, and processed in countries other than your own, including Singapore and jurisdictions where our service providers (including LearnWorlds and our AI/LLM providers) operate. Where required by applicable law, we implement appropriate safeguards for such transfers, such as standard contractual clauses or equivalent mechanisms.
Depending on your location, you may have rights to access, correct, delete, or port your personal data, to object to or restrict certain processing, and to withdraw consent to marketing communications. Singapore-based users may exercise rights under the PDPA; EU/UK users may exercise rights under the GDPR; California residents may exercise rights under the CCPA. To exercise any of these rights, contact us using the details in Section 12.
We retain personal data for as long as your account is active, and thereafter for as long as necessary to fulfil the purposes described in this Policy, comply with legal obligations, resolve disputes, and enforce our agreements. AI Coach conversation data is retained in accordance with Section 4 and deleted or anonymised on a rolling basis, or upon account deletion request, unless a longer retention period is required by law.
We implement administrative, technical, and physical safeguards designed to protect personal data against unauthorised access, alteration, disclosure, or destruction, including encryption in transit, access controls, and vendor due diligence for providers such as LearnWorlds, our payment processor, and our AI/LLM providers. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.
The Services are intended for working professionals and are not directed to individuals under the age of 18. We do not knowingly collect personal data from children. If we become aware that we have inadvertently collected such data, we will take steps to delete it.
We use cookies and similar technologies to operate the Services, remember your preferences, verify your access location for pricing eligibility purposes, and analyse usage. You can control cookies through your browser settings, though disabling certain cookies may affect the functionality of the Services.
We may update this Privacy Policy from time to time. We will notify you of material changes by posting the updated Policy on the Services and updating the “Effective Date” above. Your continued use of the Services after changes take effect constitutes acceptance of the updated Policy.
